We have addressed this scenario when dealing with DHF combination product ; and answer to that is
to map each of line item of the DHF content in two columns, one for the device itself ; and other for the drug product, at some phase or contents of DHF become common, viz., DT or DV.
i will try place it from perspective of typical ANDA, and the process should be established or evolved as we move away from ANDA perspective ( even if its labelling differences, patent non infringing designs, or new indications, or even improvements. etc )
- Design Plan - there is seldom a project plan beyond compliance or objective or reference listed drug reference, usually coming from the product development report. ( 32p2 )
- User Needs - QTPP
- Design Inputs - CQA
- Design Outputs - Control Strategy
- Risk Analysis, Including Hazard Identification - CMA & CPP assessment
- Human Factors Analysis - NA ( device reference is adequate )
- Design Verification, With Acceptance Criteria - scale up, pilot bio or bridging studies,
- Design Validation, With Acceptance Criteria - exhibit/submission batch validation reports
- Design Changes - Master production records
- Software Validation—If Applicable
- Design Reviews - Change control for moving into exhibit batch phase or validation phase.
- Design Transfer - scale up report.
hope this helps.